Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 1 of 7

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District Judge Thomas S. Zilly

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

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CITIZENS OF THE EBEYS RESERVE

FOR A HEALTHY, SAFE & PEACEFUL
ENVIRONMENT,

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No. 2:13-cv-1232-TSZ

DECLARATION OF JOSEPH J. CZECH

Plaintiff,

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v.
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U.S. DEPARTMENT OF THE NAVY;

ADMIRAL PHIL DAVIDSON, in his
official capacity as the Commander, Fleet
Forces Command; and CAPTAIN MIKE
NORTIER, in his official capacity as
Commanding Officer Naval Air Station
Whidbey Island,

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Defendants,
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I, Joseph J. Czech, Senior Lead Engineer at Wyle Laboratories, Incorporated, do hereby

declare as follows:
1. I have extensive experience modeling and studying military aircraft noise. I have reviewed the
JGL study provided by Plaintiff in this case, and have found it to be flawed. It also does not
present any new information that is significantly different than that already presented in the two
2004 Wyle Reports, the 2005 Environmental Assessment, or 2005AICUZ study.

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CZECH DECLARATION
No. 2:13-cv-1232-TSZ

-1U.S. Department of Justice

7600 Sand Point Way NE
Seattle, WA 981115

Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 2 of 7

BACKGROUND

2. I am a senior lead engineer with Wyle Laboratories, Inc. (Wyle) with a Bachelors Degree in
Aerospace Engineering from California State Polytechnic University, Pomona. I am a licensed
Professional Engineer in the State of California in the discipline of Mechanical Engineering. I
am a member of the Acoustical Society of America.

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3. I have been doing research and consulting in the field of acoustics and aircraft noise,
including noise modeling, for 27 years, mostly with my current employer Wyle Laboratories Inc.
I began conducting aircraft noise studies for Wyle for the Navy in 1993 and was Wyles
principal engineer for dozens of Navy aircraft noise studies in the 1990s. In 1994, in support of
the Base Realignment and Closure Act of 1993, I authored an aircraft noise study analyzing A6/EA-6 and P-3 aircraft operations at NAS Whidbey Island (NASWI) and Outlying Landing
Field Coupeville (OLF Coupeville). I helped develop the Navys Air Installation Compatible
Use Zone (AICUZ) Seminar and its Student Guide. I co-instructed the Seminar on two
occasions. I was one of the measurement personnel for the acoustic tests of the FA-18E/F Super
Hornet in the late 1990s. These acoustic tests furnished the reference acoustic data for the FA18E/F, upon which modeling of the EA-18G Growler is based. 1 I assisted with early modeling
of the FA-18E/F for studies related to its introduction to facilities on the East Coast of the United
States. More recently, I was Wyles project manager and principal investigator for aircraft
noise for a Supplemental EIS for the Introduction of the P-8A Poseidon at NASWI and NAS
Jacksonville. I co-authored the noise study supporting the 2012 EA for the proposed transitions
of expeditionary EA-6B Prowler squadrons to EA-18G Growler aircraft.
4. I am Wyles Project Manager for the noise study associated with the ongoing EA-18G
Growler EIS. Although I was not working with Wyle in 2004 when the Noise Study was
published, I have since become familiar with the study by reviewing the report, and underlying
data, and the AICUZ study2 that was based on the 2004 Wyle study as part of my responsibilities
for the ongoing EA-18G EIS noise study. 3
5. I have been involved with noise studies for the introduction of new aircraft. In addition to
several studies of the MV-22B Osprey, I have been the Project Manager and investigator for the
noise studies for the introduction of all three variants of the F-35 Lightning II (also known as the
Joint Strike Fighter) for the United States Air Force, Marine Corps and Navy. I have provided

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EA-18G Growler modeling with DODs NOISEMAP suite of programs utilizes the NOISEFILE
database and the FA-18E/F reference acoustic data therein.
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Pursuant to DOD Instruction 4165.57, the AICUZ program requires that air installations engage State
and local governments and communities to foster compatible land use.
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The study supporting the AICUZ was Wyle Report 04-26 Aircraft Noise Study for Naval Air Station
Whidbey Island and Outlying Landing Field Coupeville, Washington. Wyle Report 04-26 and Wyle
Report 04-08, Operational Noise Comparisons between EA-6B and EA-18G at NAS Whidbey Island
and OLF Coupeville; (Wyle Reports) support the Environmental Assessment for Replacement of EA6B Aircraft with EA-18G Aircraft at Naval Air Station Whidbey Island, Washington, (2005 EA) dated
January 2005. In this declaration, any reference to data found in the AICUZ is thus also a reference to
Wyle Report 04-26 and the 2005 EA, which incorporates Wyle Report 04-08.

CZECH DECLARATION
No. 2:13-cv-1232-TSZ

-2U.S. Department of Justice

7600 Sand Point Way NE
Seattle, WA 981115

Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 3 of 7

engineering support for the detailed acoustic measurements of the F-35A, F-35B, FA-18C/D
Hornet, FA-18E/F and MV-22B Osprey.

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6. I have authored the latest version, Version 7.3, of the core program (NMAP) of the
Department of Defenses (DOD) NOISEMAP suite of computer modeling programs, which is
used to develop contours of Day-Night Average Sound Level (DNL) around air stations and OLFs. I coauthored Version 7.0 of NMAP in 1998 which incorporated the modeling and effects of ground
elevation and impedance 4 into the computations, and I have taught DOD-sponsored training
courses for NOISEMAP on several occasions.
7. Aircraft noise modeling primarily entails the gathering and entry of information for input to
DODs NMAP program, which is part of the NOISEMAP suite of programs. NMAP requires
the following categories of information: general airfield information (runway coordinates,
weather data, etc), flight tracks, flight events and flight profiles, 5 static run-up locations, static
events and static profiles. 6 The flight tracks, events and flight profiles are specific to aircraft
type and type of operation (departure, arrival, closed pattern). For the EA-18G at the OLF this
data is also specific to time/period of day. For the computation of the Day-Night Average Sound
Level (DNL) metric, all of this information, except for the general airfield information, needs to
be applicable to a 24-hour day. All of this information is typically gathered via interviews with
station and squadron personnel and approved by them via data validation packages prior to
execution of the program.
8. The NOISEMAP suite of programs includes the NOISEFILE database, which is a database of
measured sound levels for most type/model/series of fixed-wing aircraft in the DOD inventory. 7

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9. The NMAP program computes DNL at hundreds or thousands points on the ground from the
information gathered from station and squadron personnel and from the information in the
NOISEFILE database. Another program in the suite called NMPlot produces the DNL
contours.
10. A variety of metrics can be used to measure sound. Two of them specifically for individual
aircraft events include Maximum Sound Level (Lmax) and Sound Exposure Level (SEL). As an
aircraft flies over or near you, the sound increases in intensity, reaches its maximum sound level,
and then decreases in intensity until below the ambient sound level. The maximum sound level
during the event is the Lmax. SEL is the most common measure of cumulative noise exposure for
a single aircraft flyover. If one takes all of the sound energy occurring throughout the event and

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Ground impedance is a measure of the ability of the ground cover (e.g., grass, plowed earth, water
surface) to absorb or reduce sound.
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A flight profile consists of points of altitude, power setting and speed along a flight track.
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A static event is a maintenance run-up where the aircraft or engine is stationary and is operated at
power for a duration of time. A static location is where the run-up physically occurs. A static profile
consists of power setting, duration, number of engines and heading associated with a static event.
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Type refers to the mission of the airplane, model refers to the model number, and series refers to
the generation of the aircraft. For example, for the EA-18G, EA refers to type (Electronic Attack), 18
refers to the model, and G refers to series.

CZECH DECLARATION
No. 2:13-cv-1232-TSZ

-3U.S. Department of Justice

7600 Sand Point Way NE
Seattle, WA 981115

Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 4 of 7

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compresses it into one second, the SEL is the result, which represents the total sound energy of
an event. The duration of aircraft events depends heavily on the aircrafts speed and its distance
from the receiver; most events are 10-20 seconds in duration. Because the SEL is normalized to
one second, it will almost always be larger in magnitude than the Lmax for the event.

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11. Equivalent Sound Level (Leq) is a cumulative metric in that it represents the decibel average
of all sounds in the time period for which it is intended. If Leq covers a 24-hour day, it is denoted
Leq(24).

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12. DNL is the same as Leq but penalizes sounds occurring during the DNL nighttime period
(i.e., 10 p.m. to 7 a.m., also known as DNL night or acoustic night), by 10 dB. For example,
if an aircraft event generates an SEL of 100 dB and that event occurs during the DNL nighttime
period, 10 dB is added to the SEL, making the SEL effectively 110 dB. This 10 dB penalty is
applied to account for greater sensitivity to nighttime noise. Also, events at night are often
perceived to be more intrusive because nighttime ambient noise is less than daytime ambient
noise. Another way to look at DNLs 10 dB penalty (and the way NOISEMAP computes DNL)
is that each nighttime event is equivalent to 10 daytime events. Thus, DNL is calculated by the
equation: DNL = <SEL> + 10log10(Nd + 10Nn) 49.4, where <SEL> is the decibel average
SEL by the aircraft of interest, Nd is the number of daytime (7 a.m. 10 p.m.) events by that
aircraft, Nn is the number of nighttime (10 p.m. 7 a.m.) events by that aircraft and 49.4 is
10log10 of the number of seconds in a day.
13. Energy averaging, or decibel summation, is logarithmic;8 it is not a statistical mean. This
logarithmic nature means that higher sound levels tend to dominate the Leq and DNL. As a
simple example, consider a case in which only one aircraft overflight occurs during the daytime
over a 24-hour period, creating a sound level of 100 dB for 30 seconds. During the remaining 23
hours, 59 minutes, and 30 seconds of the day, the ambient sound level is 50 dB. The DNL for
this 24-hour period is 65.9 dB. Assume, as a second example that 10 such 30-second overflights
occur during daytime hours during the next 24-hour period, with the same ambient sound level of
50 dB during the remaining 23 hours and 55 minutes of the day. The DNL for this 24-hour
period is 75.5 dB. Clearly, the averaging of noise over a 24-hour period does not ignore the
louder single events and tends to emphasize both the sound levels and number of those events.
Even Mr. Lillys extreme hypothetical example, Lilly Decl. 14, proves this point. If one days
DNL was nearly 104 dB and the other 364 days were 0 dB DNL, the resultant annual average
DNL would be 78 dB. Thus, the resultant DNL is clearly dominated by the 1-days value. The
statistical mean of these 365 daily DNLs would be less than 1 dB.

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14. DNL is the metric required by DOD for assessing aircraft noise impacts. DOD and Navy
land use compatibility guidelines generally call for the 24-hour period used to compute DNL to
be an annual average day (AAD), i.e., annual average daily aircraft operations, tracks, profiles,
etc., consistent with FAA guidelines for civilian airports. 9 Although aircraft operations at
military airfields are not constant (as they may be at civilian airports), the AAD requirement

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Logarithmic means that the value increases on orders of magnitude (i.e., a tenfold increase) rather
than a standard linear scale.
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14 CFR Part 150

CZECH DECLARATION
No. 2:13-cv-1232-TSZ

-4U.S. Department of Justice

7600 Sand Point Way NE
Seattle, WA 981115

Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 5 of 7

allows for standardization across all DOD airfields and equal treatment of aircraft noise
assessments in all services.

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15. The JGL study (the study), cited by Plaintiff, did not specify the following important
parameters typical of aircraft noise studies:
a) Which runway of the OLF was active;
b) Whether windows were open or closed at Position 5;
c) The weather conditions (temperature, relative humidity, wind speed and direction); and
d) Photographs of each noise measurement location (the study only shows photographs of
positions 1 and 4);
e) Whether the sound level meters were American National Standards Institute Type 1 or
2. 10

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16. The study had insufficient sampling (a 1-hour snapshot at 4 and 5 sites) to challenge the
AICUZs DNL results. The DOD NOISECHECK guidelines require measurements at many
(tens) of points on the ground. 11 The length of the measurement program prescribed by the
NOISECHECK guidelines varies based on the elevation angle (angle between the Point of
Interest (POI) or receiver and the aircraft) and slant distance (distance between the POI/receiver
and the aircraft), but could result in days or months of measurements. With FCLP activity
occurring at the OLF approximately 40 days per year on average, a sample size of at least 10
flying days throughout the year would be reasonable. It would also be better to measure
simultaneously at multiple sites rather than this studys strategy of a snapshot at one site and
another snapshot of a different (not necessarily overlapping) time at another site. Simultaneous
measurements allow for correlation between sites. Correlation between sites helps determine
non-aircraft noise events.
17. The maximum A-weighted 12 levels cited in the studys Table 1 for Positions 1 through 3 are
not substantiated by the studys Figures 3 through 5. For Position 1, Figure 3 does not annotate
the fast Lmax (Lmax,fast). 13 For Position 2, Figure 4 shows 112.8 dBA Lmax,fast, not 113.4 dBA.
For Position 3, Figure 5 shows 115.1 dBA Lmax,fast, not 115.7 dBA.

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The type of sound level meter dictates the accuracy. Type 1 is up to 1 dB more accurate than Type 2.
Type 1 is standard practice for community/aircraft noise while Type 2 is acceptable for general purpose
noise surveys/OSHA.
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Bishop et al 1980. Bishop, Dwight E.; Harris, Andrew; Mahoney, Joan; and Rentz, Peter E., 1980.
NOISECHECK Procedures for Measuring Noise Exposure from Aircraft Operations. Bolt, Beranek, and
Newman Inc., November 1980.
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Sounds with different spectra are perceived differently even if the sound levels are the same. Weighting
curves have been developed to correspond to the sensitivity and perception of different types of sound.
A-weighting is one of two of the most common weightings. The A-weighting mimics the sensitivity of
the human ear to non-impulsive sounds such as aircraft noise, de-emphasizing the content of the sound
below 1,000 Hertz (Hz) and higher than 4,000 Hz while emphasizing the content of the sound between
1,000 and 4,000 Hz. An impulsive type of sound would be a bang or an explosion. Such emphasis is
made because the human ear is less sensitive to low frequency sound than mid-high frequency sounds
from non-impulsive sources.
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Most sound level meters (SLM) have two settings slow and fast. On the slow setting, the SLM
averages sound every second and outputs the resultant level. On the fast setting, the SLM averages

CZECH DECLARATION
No. 2:13-cv-1232-TSZ

-5U.S. Department of Justice

7600 Sand Point Way NE
Seattle, WA 981115

Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 6 of 7

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18. The maximum A-weighted levels cited in the studys Table 1 are misleading because they
used the fast setting on the sound level meter. Noise measurements of aircraft in the vicinity
of airfields typically use the slow setting on sound level meters. Although the study states it
measured one-second Leq values on page 1, it inconsistently reports Lmax,fast in Table 1.
19. The studys Table 1 overstates the maximum sound levels during the events. The maximum
one-second Leq values for Positions 1 through 5 were 116.6 dBA, 110.9 dBA, 112.1 dBA, 114
dBA and 81.1 dBA, respectively. These maximum one-second Leq values are up to 3.6 dB less
than the mostly Lmax,fast values in Table 1.

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20. The study does not substantiate its claim on page 2 that some hearing damage criteria are
based on the un-weighted peak sound pressure level.
21. The study states that the chosen measurement locations represent populated areas where people could be exposed to the aircraft noise without necessary hearing protection and that one
of the purposes of the study was to determine whether there is a need to examine possible
impacts on the health and well-being of those exposed. The best choice of the type of location
to fulfill these purposes would be locations representing residential land use. However, both
Positions 2 and 4 represent locations with only transient, not long-term population. Position 2 is
a bird watching platform at beach near ferry dock. The land use at Position 4 (Rhododendron
Park Baseball Field) is recreational and its population is seasonal and temporary at best.
Positions 2 and 4 are not representative of residential land use in the vicinity of the OLF.
22. The studys Table 2 presents durations above various sound thresholds but does not tie them
to OSHA or DOD hearing loss criteria. Note that Table 2 is only for 1 session of FCLPs.
Although an outdoor DNL of 80 dB is the DODs screening criteria for the potential for hearing
loss (mostly at Position 1), DOD generally recognizes that it would require decades of
continuous outdoor exposure to such or similar levels, on the order of 40 years, to affect a
minimally noticeable hearing loss of 5 dB. 14

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23. The studys Table 3 is based on extrapolating part of a particular days measurements
whereas the AICUZ study was based on annual average daily operations (24-hours). The study
is making a false comparison between the JGL collected data and the data found in the AICUZ.
To make an accurate comparison, either the AICUZs DNLs would have to be adjusted to reflect
the days measurements, i.e., to the counts of aircraft events during the sessions, or DNL would
have to be computed from the measured SELs and numbers of events. Also, Table 3 compares
the 2005 AICUZs results to various combinations of DNL daytime and nighttime FCLP
sessions without justification or explanation of the combinations. For example, it shows 2
daytime sessions and 2 night sessions in bold implying that is what was being flown by the
Navy. Checking the calculations in Table 3, Mr. Lilly incorrectly assumes a Navy night

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sound every one-eighth of a second and outputs the resultant level. It is customary to report data from the
slow setting for aircraft noise measurements like the kind Lilly did.
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Department of Defense Noise Working Group, Technical Bulletin, Noise-Induced Hearing
Impairment, July 2012.

CZECH DECLARATION
No. 2:13-cv-1232-TSZ

-6U.S. Department of Justice

7600 Sand Point Way NE
Seattle, WA 981115

Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 7 of 7

Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 1 of 4

Exhibit 1

Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 2 of 4

7.2 LowFrequencyNoise
The sound levels in this report are in A-weighted decibels. Sound frequency is the number of times per
second the air vibrates or oscillates per second and has units of Hertz (Hz). The normal human ear can
detect sounds that range in frequency from about 20 Hz to about 15,000 Hz. All sounds in this wide range
of frequencies, however, are not heard equally by the human ear, which is most sensitive to frequencies in
the 1,000 to 4,000 Hz range. Weighting curves have been developed to correspond to the sensitivity and
perception of different types of sound. A- and C-weightings are the two most common weightings and are
shown in Figure 7-3. A-weighting accounts for frequency dependence by adjusting the very high and very
low frequencies (below approximately 500 Hz and above approximately 10,000 Hz) to approximate the
human ears lower sensitivities to those frequencies. C-weighting is nearly flat throughout the range of
audible frequencies, hardly de-emphasizing the low frequency sound while approximating the human ears
sensitivity to higher intensity sounds.

Relative Level (decibel)

10

-10

-20
A-weighted
C-weighted

-30

-40
31.5

63

125

250

500

1000 2000 4000 8000 16000

Frequency (Hertz)

Source: ANSI S1.4A -1985 Specification of Sound Level Meters

Figure73FrequencyResponseCharacteristicsofAandCWeightingNetworks

These two weightings are adequate to quantify most types of environmental noises. Aircraft noise is
assessed for land use compatibility in terms of A-weighted decibels (of Day-Night Average Sound Level).
To assess the potential for structural vibration, rattle or damage, C-weighting is utilized.
Normally, the most sensitive components of a structure to airborne noise are the windows and,
infrequently, the plastered walls and ceilings. An evaluation of the peak sound pressures impinging on the
structure is normally used to determine the possibility of damage. In general, with peak sound levels above
130 dBC, there is the possibility of the excitation of structural component resonances. While certain
frequencies (such as 30 Hz for window breakage) may be of more concern than other frequencies,
conservatively, only sounds lasting more than one second above a sound level of 130 dBC are potentially
damaging to structural components (Committee on Hearing, Bioacoustics, and Biomechanics 1977).

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Exhibit 1 to Czech Declaration

Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 3 of 4

Noise-induced structural vibration may also cause annoyance to dwelling occupants because of induced
secondary vibrations, or rattling of objects within the dwelling such as hanging pictures, dishes, plaques,
and bric-a-brac. Window panes may also vibrate noticeably when exposed to high levels of airborne noise.
In general, such noise-induced vibrations occur at peak sound levels of 110 dBC or greater. Assessments
of noise exposure levels for compatible land use should address the potential for noise-induced secondary
vibrations.
NASWI has received complaints of building rattle/vibration due to Growler events. Figure 7-4 shows the
unweighted one-third octave band spectra from the acoustic reference database (Noisefile). It is important
to note that the databases condition is for the aircraft at an altitude of 1000 ft AGL and the receiver
located on the ground directly below the aircraft. The Growlers unweighted spectral levels are, on
average, 11 dB greater than the Prowler during a Mil power takeoff passing through 1000 ft AGL for
frequencies less than 50 Hz. For approaches and cruise power at 1000 ft AGL the frequency spectra of
the two aircraft are similar for frequencies less than 50 Hz with average differences of 3 to 5 dB. With its
increased low-frequency content, the Growler takeoff events have higher potential to cause noise-induced
vibration.
Using the acoustic reference data, the overall C-weighted sound levels for both aircraft for these three
conditions are contained in Table 7-4. Due to the EA-6Bs spectra sound levels, especially in frequencies
minimally affected by the C-weighting, C-weighted sound levels for the EA-6B and EA-18G only differ by
1-2 dBC for the takeoff and approach conditions. In cruise flight, the C-weighted sound levels for the EA6B are approximately 8 dBC greater than EA-18G. None of these conditions cause C-weighted sound
levels to exceed 130 dBC and structural damage would not be expected, however, the takeoff condition
has C-weighted sound levels greater than 110 dBC for both aircraft, creating an environment conducive to
noise-induced vibration. Additional analysis is recommended to more accurately determine the potential
for building rattle/vibration.
Table74CweightedSoundLevels,1000ftAGL

Condition
Takeoff
Approach
(gear
down)
Cruise

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No. 2:13-cv-1232-TSZ

EA-6B
116

EA-18G
115

EA-18G
Relative
to EA-6B
-1

111

109

-2

109

101

-8

WR1022(October2012)
Exhibit 1 to Czech Declaration

Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 4 of 4

100

EA-6B = 95% RPM

EA-18G = 96% NC

80

C-weighted Sound Levels

EA-6B = 116 dBC
EA-18G = 115 dBC

60

40
10
a)

100

Frequency (Hz)

1000

10000

Takeoff

100

80
EA-6B = 85% RPM
EA-18G = 85% NC
60

40
10
b)

100

Frequency (Hz)

1000

10000

Cruise

100

80

EA-6B = 85% RPM

EA-18G = 84% NC

60

C-weighted Sound Levels

EA-6B = 111 dBC
EA-18G = 109 dBC

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10
c)

100

Frequency (Hz)

1000

10000

Approach

Figure74ComparisonofSoundSpectraforEA6BandEA18G(1000ftAGL,59F,70%RH)

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Exhibit 1 to Czech Declaration